In Facebook's seven count complaint against Defendant MaxBounty Inc. for its allegedly fraudulent advertising scheme aimed at Facebook users, the social networking giant defeated MaxBounty's motion to dismiss Facebook's claim under the CAN-SPAM Act by successfully arguing that the fake advertising pages posted by MaxBounty on the social networking site constituted "electronic mail messages" under the Act. Facebook, Inc. v. MaxBounty, Inc., No. CV-10-4712-JF, 2011 WL 1120046 (N.D. Cal. Mar. 28, 2011). The District Court for the Northern District of California held that Facebook sufficiently pled its claim under 15 U.S.C. § 7701 ("CAN-SPAM Act"), thereby adopting Congress' broad interpretation of the term "electronic mail message."